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Re: [RFI] ARRL to FCC...

To: "Hare, Ed W1RFI" <w1rfi@arrl.org>
Subject: Re: [RFI] ARRL to FCC...
From: "Dale J." <dj2001x@comcast.net>
Date: Wed, 23 Jul 2014 15:22:14 -0500
List-post: <rfi@contesting.com">mailto:rfi@contesting.com>
Thanks Ed,

So you actually have looked at some of this paper yourself?

Yes, I am speculating, but having had experience with this from my previous 
work, I know for a fact that some certifications can be as I described and 
highly rejectable, maybe not in this instance or with these items.  

Anyway I'm happy to know our voice in Washington is doing it's best and with 
our best interests in mind.  I appreciate your work.  I just wish that the 
burden of a proof and a solution weren't on ours and our neighbors shoulders, 
pitting neighbor against neighbor about TV interference or plasma TV noise is 
contrary to living as we all would like, in peace and harmony. 

I also am a member of ARRL and have been for over 50 years, hi, time sure goes 
by fast.  

Dale, k9vuj

On 23, Jul 2014, at 14:54, "Hare, Ed  W1RFI" <w1rfi@arrl.org> wrote:

> Hi, Dale,
> I have seen issues with many of the certification reports approved by the 
> TCBs, but most are not really impacting the EMC performance of the product, 
> so are generally "harmless."
> The certification reports are not really boilerplate, but consist of a number 
> of pages of test data and real signatures, so that speculation does miss the 
> mark a bit. 
> The majority of products we have tested have met the requirements, to all 
> that wiggle room you fear is really not being used.
> Ed
> -----Original Message-----
> From: Dale J. [mailto:dj2001x@comcast.net] 
> Sent: Wednesday, July 23, 2014 1:20 PM
> To: Hare, Ed W1RFI
> Cc: mstangelo@comcast.net; kgordon2006@frontier.com; rfi@contesting.com 
> Reflector
> Subject: Re: ARRL to FCC...
> I know it's not very practical to hire a bunch of FCC inspectors to check 
> each and every product that's sold.  However, spot checking of these 
> requirements should be within the reach of one of the government agencies.  
> For example, we have a Homeland security agency which scans each and almost 
> every passenger that gets on commercial aircraft yet we have tons of 
> fireworks that are distributed all across the nation, both imported and mfg 
> inside the country yet nothing is done about that.  It's like we do, but we 
> don't.  That goes for junk products that's imported and put on shelves of the 
> big box stores eventually making it's way to your neighbors house, then we're 
> expected to clean up the mess.  
> I'd love to be that mouse in the corner when #'s 1,2,3 are processed.  Better 
> yet, I'd love to be on the audit team which checks to see if #'s 1,2,3 are 
> being performed as required (if there even is such a thing). I'll bet I could 
> find a zillion things wrong with the processes.  The certifications are 
> probably boiler plate copies with blanks filled in and no traceability, 
> signature blocks typed in or no signature of a responsible party even on the 
> paper.  
> All three have lots of wiggle room to skate by requirements.  
> Dale, K9VUJ
> On 23, Jul 2014, at 10:56, "Hare, Ed W1RFI" <w1rfi@arrl.org> wrote:
>> The FCC has not tested equipment for authorization in over 40 years.  There 
>> are 3 main levels of authorization for equipment:
>> 1. Certification.  The manufacturer submits test data to the FCC and it or 
>> one of its Technical Certification Bodies approves the design for 
>> manufacture.  Intentional emitters are subject to certification.  Computers 
>> can also be certified if the manufacturer chooses to do so.
>> 2. Verification. The manufacturer is required to ensure that the product 
>> complies with the rules. The vast majority of Part 15 and Part 18 deices are 
>> verified, with no FCC involvement.
>> 3. Declaration of Conformity.  In this case, the manufacturer tests it, but 
>> must use an approved lab.  Most computers are authorized under a DoC.
>> 73, Ed, W1RFI
>> -----Original Message-----
>> From: RFI [mailto:rfi-bounces@contesting.com] On Behalf Of 
>> mstangelo@comcast.net
>> Sent: Friday, March 21, 2014 12:30 PM
>> To: kgordon2006@frontier.com
>> Cc: Dale J.; rfi@contesting.com Reflector
>> Subject: Re: [RFI] ARRL to FCC...
>> Ken brings up a good point.
>> How many of us buy goods on ebay which is shipped directly form China 
>> because the price is right.
>> How many of us check to see if it meets FCC Part 15?
>> The most effective oversite is if the FCC tested every piece of electronic 
>> equipment. It would severly delay the introduction of electronic devices to 
>> the marketplace and jack up the price. Unfortunately this is not practical.
>> Mike N2MS
>> ----- Original Message -----
>> From: Kenneth G. Gordon <kgordon2006@frontier.com>
>> To: Dale J. <dj2001x@comcast.net>, rfi@contesting.com Reflector 
>> <rfi@contesting.com>
>> Sent: Fri, 21 Mar 2014 15:40:24 -0000 (UTC)
>> Subject: Re: [RFI] ARRL to FCC...
>> On 21 Mar 2014 at 9:37, Dale J. wrote:
>>> have to live next door to my neighbors.  That's why I would like to 
>>> see better oversight of potential RFI generators being sold to the 
>>> general public.  The ultimate burden should, must be placed on the 
>>> manufacturer of the errant product, not on the end user or me.
>> The U.S. gummint has no authority whatever over manufacturers in other 
>> countries, especially China.
>> The only ones our gummint can go after are the importers and sellers.
>> Ken Gordon W7EKB
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